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Title X Gag Rule Comments

Do you believe everyone should have equal and equitable access to safe sexual and reproductive healthcare? Currently, Title X makes it possible for everyone, regardless of income, gender, or race, to receive medically accurate and confidential care, however the Trump administration is working to take that away.
On June 1st, the Trump administration’s Department of Health and Human Services (HHS) announced a proposed rule that would make drastic changes to Title X, the only program in the United States that focuses on affordable access to contraception and other reproductive health care, including pap smears, breast exams, and STI tests. The proposed rule would make it impossible for millions to receive birth control and preventative care from places like Planned Parenthood, prohibit doctors, nurses, and other health professionals from referring patients to safe abortions, and remove the guarantee that Title X patients receive information on all their options, opening the door for participation of crisis pregnancy centers in the program.
Because this is a proposed rule, HHS must accept public comments on the proposed rule until 11:59pm on July 31st. To submit comments, head to this link and click on the “Comment Now” button on the top right side of the page. Feel free to use the sample comment we’ve included, add your own thoughts to the sample comment, or draft your own unique comment. Listed below are some ideas to help get you started:
  • Raise specific comments and questions about how the rule will impact various communities, regions, and the provision of services
  • Uplift unique experiences and considerations that are relevant to your state, region, community, organization or the services you provide, or in relation to specific population groups like women of color, those who are uninsured/ underinsured, young people, survivors of intimate partner violence, and any other vulnerable groups
  • If you are referring to a specific population and are describing the impact of the rule on that population, consider asking HHS if it has conducted any kind of evaluation about the impact of this rule on that population
  • If you rely on Title X services in your area for all reproductive care, consider asking HHS if they’ve done any studies about healthcare access and quality in areas where there are no Title X services or comprehensive family planning clinics
  • Ask if HHS has calculated the economic impacts of this rule and how it would specifically impact you and your community economically
  • Mention specific public health issues in your area or community, like sexually transmitted infections (STIs), unplanned pregnancy, breast cancer, and other health disparities, and explain how compliance with this rule will worsen these conditions; ask if HHS has any plans to assess the public health impacts of this rule
  • Ask if entities like crisis pregnancy centers, who do not offer accurate medical information and purposeful mislead women to prevent them from accessing abortion and most contraceptive methods, be able to participate in the Title X program and share your story of accessing services through legitimate clinics like Planned Parenthood and local clinics in your community and the impact these centers have had on your community
  • Explain how access to the full scope of reproductive healthcare options has impacted you and ask if HHS has considered the ethics of this rule

Sample Comment:

I oppose the proposed rule entitled Compliance with Statutory Program Integrity Requirements, which was published in the Federal Register on June 1, 2018.  The proposed rule would significantly and detrimentally alter the Title X Family Planning Program (Title X), which has provided vital sexual and reproductive health services to people across the country for more than 40 years.
Title X programs serve a diverse population that deserve access to the full spectrum of information regarding their reproductive and sexual health, especially since many of these populations already face immense barriers to accessing healthcare and experience unique health disparities. The populations who will be most impacted are low income individuals, those who are uninsured or underinsured, those who identify as female, Black, and/or Hispanic, young people, and survivors of sexual violence and intimate partner violence. Has HHS evaluated the impacts of this rule on these specific communities, especially the public health and economic impacts? The aforementioned communities will be disproportionately impacted by this ruling, just like they are disproportionately impacted by preventable sexual and reproductive health conditions like unintended pregnancy, teen pregnancy, STI rates, cervical cancer rates, and breast cancer rates. Many survivors of sexual violence and intimate partner violence depend on guaranteed confidentiality when accessing healthcare. Has HHS conducted any studies looking at whether this population will access healthcare that is not confidential, and if they do not access the services, how is their health and wellness impacted?
The proposed rule has been flagged by several provider organizations, like the American Medical Association and the American Nurses Association, who have offered statements of ethical concern. Compliance with this rule would prohibit abortion referrals, which would deny people access to complete medical information and the full spectrum of care that they deserve. Abortion is an integral part of family planning care, and individuals should know where to access one if needed. This rule also seems to encourage fake women’s health centers, colloquially known as crisis pregnancy centers, to apply to the Title X program which would be detrimental to the overall health of our country, since these centers routinely lie to clients, and offer incorrect and misleading medical facts to patients on abortion, contraception, sex, and conception. Has HHS evaluated the impact of these crisis pregnancy centers on health of specific, at risk, populations? Has HHS explored the health and wellness impacts of limiting abortion access and referral?
As an individual who believes every person, regardless of their race, gender, income, or experience deserve factual, confidential, and safe medical services, including access to abortion and the full spectrum of reproductive and sexual healthcare, I oppose the proposed rule.

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We fight for a future that includes access to all reproductive health care no matter your zip code or employer. Maryland must lead the charge. Are you with us?